The U.S. Court of Appeals for the Ninth Circuit affirmed a lower court's decision to exclude expert testimony and grant summary judgment in favor of RV manufacturers in a product liability lawsuit involving a camping device that allegedly malfunctioned and caused severe burns.
In *Jensen v. Camco Manufacturing, LLC* (9th Cir. 2026), plaintiff Erick Jensen appealed the U.S. District Court for the District of Arizona's order excluding expert testimony and granting summary judgment for defendants Camco Manufacturing, LLC and CWI, LLC, which does business as Camping World.
The case centers on Jensen's purchase of a Camco Little Red Campfire device sold by Camping World. According to court documents, while Jensen was using the campfire, flames "exploded" from the device, causing severe burns to his leg. Jensen subsequently filed a product liability action against the manufacturers and retailer.
The district court, presided over by Judge David G. Campbell, excluded Jensen's expert testimony and granted summary judgment in favor of the defendants. Jensen appealed this decision to the Ninth Circuit, challenging both the evidentiary ruling and the summary judgment grant.
The three-judge panel, consisting of Circuit Judges Hawkins, Rawlinson, and M. Smith Jr., unanimously concluded the case was suitable for decision without oral arguments. The court applied established precedent from *City of Pomona v. SQM N. Am. Corp.* (9th Cir. 2014), reviewing the summary judgment ruling de novo while examining evidentiary rulings for abuse of discretion.
The Ninth Circuit's unpublished memorandum decision, filed Jan. 8, 2026, provides limited detail about the specific grounds for affirming the district court's rulings. However, the case highlights ongoing challenges plaintiffs face in product liability litigation, particularly regarding the admissibility of expert testimony under federal evidence standards.
Expert testimony plays a crucial role in product liability cases, as plaintiffs typically must establish that a product defect caused their injuries. Courts apply rigorous standards under Federal Rule of Evidence 702 and the Supreme Court's decisions in *Daubert v. Merrell Dow Pharmaceuticals* and subsequent cases to determine whether expert testimony is reliable and relevant.
The exclusion of expert testimony often proves fatal to product liability claims, as plaintiffs frequently cannot establish causation or defect without qualified expert opinions. In this case, the district court's decision to exclude Jensen's expert testimony appears to have left him without sufficient evidence to proceed to trial.
The defendants in this case represent significant players in the recreational vehicle industry. Camco Manufacturing produces various RV accessories and camping equipment, while CWI LLC operates as Camping World, one of the nation's largest RV retailers with hundreds of locations across the United States.
Product liability cases involving camping and RV equipment have become increasingly common as outdoor recreation has grown in popularity. These cases often involve allegations of design defects, manufacturing flaws, or inadequate warnings about potential hazards associated with portable heating and cooking devices.
The Ninth Circuit's decision to issue an unpublished memorandum rather than a full published opinion indicates the court viewed this as a routine application of established law rather than addressing novel legal questions. Under Ninth Circuit Rule 36-3, unpublished dispositions are not precedential except in limited circumstances.
For Jensen, the affirmance represents the end of his federal court litigation unless he seeks further review. The Supreme Court accepts only a small percentage of petitions for certiorari, and cases involving routine application of evidentiary standards rarely receive high court review.
The case also illustrates the practical challenges facing individual plaintiffs in product liability litigation against well-resourced corporate defendants. The costs associated with retaining qualified experts and conducting extensive discovery can be prohibitive, particularly when courts apply strict standards for expert testimony admissibility.
Industry observers note that manufacturers of camping and outdoor equipment continue to face liability exposure as consumer use of such products increases. However, successful product liability claims require plaintiffs to navigate complex evidentiary requirements and overcome defendants' resources and legal expertise.
The timing of this decision, early in 2026, may influence similar cases pending in federal courts across the Ninth Circuit's jurisdiction, which includes Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington.
While the specific details of Jensen's expert testimony and the reasons for its exclusion remain unclear from the published decision, the case serves as a reminder of the high evidentiary bar plaintiffs must meet in federal product liability litigation.
The defendants' successful motion for summary judgment demonstrates the effectiveness of challenging expert testimony as a litigation strategy, particularly in cases where plaintiffs rely heavily on technical evidence to establish their claims.